Compliance officers are experts at spotting red flags. They can discern potential FCPA violations from the other side of the world. But what about red flags closer to home — those that might impact a compliance professional’s career?… Continue Reading
Today’s hyper-transparent environment has given the public stunning opportunities to review internal communications from executives at leading companies and to pass real-time judgments on the strengths and vulnerabilities of their cultures.… Continue Reading
The European Investment Bank’s Inspectorate General Investigation Division started conducting Proactive Integrity Reviews (PIRs) in 2010, with the main objective to identify potential vulnerabilities and major fraud risks of EIB-funded operations and projects.… Continue Reading
As long as U.S. federal law enforcement priorities remain the same, licensed cannabis operators are unlikely to be prosecuted if they are completely compliant with state laws. However, if the DOJ or state regulators discover that a license was acquired through corrupt means, the license will not provide any protection.… Continue Reading
I see it time and time again — third parties that would otherwise pass muster under a client’s due diligence process create their own red flags.
They push back on a local registration requirement.… Continue Reading
Working with third parties continues to be the single biggest corruption risk for business. Almost one in two enforcement actions concluded since the OECD Anti-Bribery Convention came into force in 1999 was the result of bribery through sales agents, intermediaries, distributors or brokers.… Continue Reading
In the majority of bribery and corruption investigations — from relatively simple matters to complex cross-border affairs — the data necessary to detect and solve these cases was largely available within the organization under investigation and could have been used to prevent the red flag from erupting into a full-blown scandal.… Continue Reading
The SEC alleged Wednesday that two former anti-money laundering compliance officers for a New York broker dealer aided and abetted their firm’s AML violations.
One of the compliance officers settled the SEC charges.… Continue Reading
Recent enforcement actions suggest that regulators, both in the United States and the UK, are targeting compliance officers.
Some of these cases involve allegations that compliance officers took part in the misconduct, such as collusion between a compliance officer of a registered broker-dealer and his relatives to defraud investors and embezzle their money.… Continue Reading
The Huffington Post/Fairfax Media’s report of bribery at Unaoil is another cautionary tale on how entire industries can find themselves under investigation for use of the same intermediary.
I worked in corporate investigations from 2003 to 2011.… Continue Reading
In a speech this week to compliance professionals at the European Compliance and Ethics Institute in Prague, the general counsel of the UK Serious Fraud Office talked about attorney-client privilege in connection with SFO corruption investigations.… Continue Reading